Appendix F: Monitoring framework

Propose an additional monitoring indicator of;

• Number of planning applications delivering a BNG in excess of 10%

See attached representation.

We have reviewed the publicly available Local Plan documents and provided comments in the attached letter, in relation to the transport implications of the plan for the safety and operation of the SRN.
Our comments include issues to resolve, comments, requests for further information and recommendations. A brief summary of our main comments are:
- the reliance on the delivery of the A27 Chichester bypass improvements project.
- the requirements for new, additional, and adapted processes and assessments, especially in assessing Transport Assessments, mandating Travel Plans and monitoring traffic associated with new developments.
- collaborative working between agencies in combination with a robust monitor and manage policy.
We hope our comments assist.
To date National Highways have worked collaboratively with Chichester District Council (the Council) and West Sussex County Council (WSCC) and we will continue to work with the Council and other key stakeholders. We look forward to continuing to participate in future consultations and discussions.
Once you have had the opportunity to digest all the representations received, we would welcome a meeting to run through all the transport related matters and agree how to progress any required evidence gathering or other work.

Background

National Highways has been appointed by the Secretary of State for Transport as strategic highway company under the provisions of the Infrastructure Act 2015 and is the highway authority, traffic authority and street authority for the strategic road network (SRN).

National Highways is responsible for operating, maintaining, and improving the Strategic Road Network (SRN) i.e., the Trunk Road and Motorway Network in England, as laid down in Department for Transport (DfT) Circular 01/2022 (Strategic Road Network and the delivery of sustainable development).

The SRN is a critical national asset and as such we work to ensure that it operates and is managed in the public interest, both in respect of current activities and needs as well as in providing effective stewardship of its long-term operation and integrity.

Our responses to Local Plan consultations are guided by relevant policy and guidance including the National Planning Policy Framework (2021) (NPPF):

• Transport issues should be considered from the earliest stages of plan-making and development proposals so that the potential impact of development on transport networks can be addressed (para 104).

• The planning system should actively manage patterns of growth such that significant development is focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes. (para 105).

• Planning policies should be prepared with the active involvement of highways authorities and other transport infrastructure providers so that strategies and investments for supporting sustainable transport and development patterns are aligned. (para 106).

• In terms of identifying the necessity of transport infrastructure, NPPF confirms that development should only be prevented or refused on highways grounds if there would be an unacceptable impact on highway safety, or the residual cumulative impacts on the road network would be severe. (para 111).

• Planning policies and decisions should support development that makes efficient use of land, taking into account the availability and capacity of infrastructure and services – both existing and proposed – as well as their potential for further improvement and the scope to promote sustainable travel modes that limit future car use. (para 124).

In relation to the tests of soundness set out at paragraph 35 of the NPPF, in the context of transport, these are interpreted as meaning:

a) Positively prepared - has the transport strategy been prepared with the active involvement of the highway authorities, other transport infrastructure providers and operators and neighbouring councils?
b) Justified – Is the transport strategy based on a robust evidence base prepared with the agreement in partnership, or with the support of the highway authorities?
c) Effective – Does the transport strategy and policy satisfy the transport needs of the plan and is it deliverable at a pace which provides for and accommodates the proposed progress and implementation of the plan?
d) Consistent with national policy – Does the transport strategy support the economic, social, and environmental objectives of the Plan and the NPPF/NPPG?

We will be concerned with proposals that have the potential to impact on the safe and efficient operation of the SRN; in this case, the A27 trunk road (Chichester Bypass and its junctions) which is the main access route in the Chichester area. We have particular interest in any allocation, policy or proposals which could have implications for the A27 and the wider SRN network. We are interested as to whether there would be any adverse road safety or operational implications for the SRN. The latter would include a material increase in queueing or delay or reduction in journey time reliability during the construction or operation of the development set out in the plan.

National Highways is a key delivery partner for sustainable development promoted through the plan-led system, and as a statutory consultee we have a duty to cooperate with local authorities to support the preparation and implementation of development plan documents.

In accordance with national planning and transport policy and our operating licence, we are entirely neutral on the principle of development as it is for the local planning authority to determine whether development should be allocated or permitted; albeit it must comply with national policy on locating development in locations that are or can be made sustainable. Therefore, while always seeking early and fulsome engagement with local plans and/or developers, we will simply be assessing the transport and related implications of plans or proposals and agreeing any necessary transport improvements and relevant development management policy.

In progressing Local Plans, we will seek to agree the following:
• Assessment tools and methodology
• Baseline Assessment i.e., to demonstrate that the assessment tool accurately reflects current transport conditions
• Comparator case assessment i.e., to forecast the transport conditions that would occur in the absence of the plan
• Forecast modelling i.e., to forecast the transport conditions that would arise with the plan in place, this will include an assessment at the end of the Plan period; and, if required, at full build out if that occurs after the end of the Plan period
• Outputs and outcomes of modelling, demonstrating, as appropriate, what transport infrastructure is necessary to support the plan o It should be noted that a suite of transport modelling tools may be required. This includes strategic modelling covering an area at least one major junction beyond the district boundary, localised network modelling where several links/junctions are close together and/or individual junction modelling
o A DMRB (Design Manual for Roads and Bridges) compliancy assessment may also be required for certain highway features, such as
Merge/Diverge assessment at Grade separated junctions, link capacity assessments, and others.
• The design of any necessary transport infrastructure, to an extent suitable for establishing deliverability during the plan period at the time that it becomes necessary for the purpose of ensuring that unacceptable road safety impacts or severe operational impacts do not arise as a result of development. This may be to at least General Arrangement design stage or preliminary design stage. Whichever degree of detail is agreed, the products must be in full compliance with the DMRB.
• Industry standard transport intervention costings.
• The delivery/funding mechanisms for necessary transport interventions. It should not be assumed that National Highways will have any responsibility to identify or deliver necessary transport interventions.
• If considered appropriate, a “Monitor & Manage” (M&M) framework, aimed at managing the pace of development in line with the pace of funding and delivery of necessary highway interventions in a manner which responds to the realworld impacts of development may be agreed for inclusion in the plan subject to the adequacy of risk control measures included therein. This can include the move from a ‘predict & provide’ style of delivery to ‘a vision & validate’ style. o Any M&M framework must be based on a “worst case scenario” whereby necessary mitigation is understood, as well as setting out the desired alternative scenario. It must set out details of responsibility, funding and governance of the framework together with the methodology for determining the timing for any mitigation delivery while remaining clear on the fallback position where identified mitigation or desired alternatives are not ultimately achievable. It must be translated into development management plan policy and policy relating to development allocations.

Further detail on the above can be provided by National Highways.

While ideally all the above should be agreed prior to the Submission of the Local Plan for examination, we recognise that this is not always possible. However, all parties should work towards all matters being agreed and reflected in a Statement of Common Ground (SoCG) by the start of the Local Plan Examination at the latest. Ideally the SoCG between the Council and National Highways would be prepared well in advance of plan submission in order to guide resource input and to track progress towards final agreement on all relevant matters starting from the earliest plan iterations until the final version is agreed.

It is acknowledged that Government policy places much emphasis on housing delivery as a means for ensuring economic growth and addressing the current national shortage of housing. The NPPF is very clear that:
“Strategic policy-making authorities should establish a housing requirement figure for their whole area, which shows the extent to which their identified housing need (and any needs that cannot be met within neighbouring areas) can be met over the plan period.”

However, new DfT C1/22 and the NPPF are equally clear that any development, including housing delivery, must be tempered by the requirement to ensure that the associated transport demand can be accommodated without unacceptable impacts on the safety of the SRN or severe impacts on the operation of the SRN including reliability and congestion. Therefore, as necessary and appropriate, any plan and/or development must be accompanied by suitable mitigation in the right places at the right time, that is to the required design standards and is deliverable in terms of land availability, constructability and funding.

We would also draw your attention to the then Highways England document ‘The Strategic Road Network, Planning for the Future: A guide to working with National
Highways on planning matters’ (September 2015). This document sets out how National Highways intends to work with local planning authorities and developers to support the preparation of sound documents which enable the delivery of sustainable development. https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachmen t_data/file/461023/N150227_-_Highways_England_Planning_Document_FINAL-lo.pdf

Responses to Local Plan consultations are also guided by National Planning Policy Framework (NPPF) revised on 20 July 2021 which sets out the government’s planning policies for England and how these are expected to be applied.

Updated Circular (01/2022)
It should be noted that since the start of the Local Plan consultation process, on the 23 December 2022, the Department for Transport released a new circular on the ‘Strategic road network and the delivery of sustainable development’ (Circular 01/2022), which replaces all of the policies in Circular 02/2013 of the same name. These representations take account of the new circular and the requirements in terms of the Local Plan evidence base and process.

We request that the Local Plan is prepared in line with all aspects of the new circular. Particularly, the principles of sustainable development (paragraphs 11 to 17), new connections and capacity enhancements (paragraphs 18 to 25), and engagement with plan-making (paragraphs 26 to 38).

Regulation 18 submission
In our Regulation 18 submission we noted several matters including:
• The need to mitigate the adverse impacts of strategic development traffic to the A27 Chichester Bypass and its junctions at Portfield Roundabout, Bognor Road Roundabout, Whyke Roundabout, Stockbridge Roundabout and Fishbourne Roundabout and Oving junction.
• The need to identify a mechanism to calculate contributions towards the delivery of the previously agreed Local Plan A27 improvements
• The need to confirm the number of dwellings needed within the plan period
• The need to establish National Highways acceptance of the traffic model reference and future case scenarios
• The need to confirm costs, viability, and funding associated with mitigating the safety and congestion impacts of the development included within the plan.

Local Plan context
This Local Plan (Chichester Local Plan 2021 – 2039), prepared by the Local Planning Authority (LPA) Chichester District Council, sets out the vision for future development in the district and will be used to help decide on planning applications and other planning related decisions including shaping infrastructure investments.

The draft sets out how the district should be developed over the next 18-years to 2039 including for the full Plan period (1 April 2021 to 31 March 2039) the total supply of
- 10,359 dwellings
- 114,652 net additional sqm new floorspace
Minus the completions this is equivalent to around 530 dwellings and 6,150 sqm of floorspace a year.

National Highways Representations
To date National Highways have worked collaboratively with Chichester District Council (the Council) and West Sussex County Council (WSCC) and we will continue to work with the Council and other key stakeholders.

We have undertaken a review of the Chichester Local Plan 2021-2039 proposed submission version and accompanying evidence documents, our comments are set out in the tables below (following pages). [see table within attachment]

Summary

We have reviewed the publicly available Local Plan documents and provided comments above in relation to the transport implications of the plan for the safety and operation of the SRN. We understand that other technical information is available, but this was not presented as part of this consultation.
Chichester, and the A27, are already heavily congested, infrastructure in the existing Local Plan remains undelivered and the growth set out in the new Plan will further increase travel demand.
As presented, satisfying the transport needs of the plan is clearly reliant on the delivery of the A27 Chichester bypass improvements project. The A27 Chichester bypass improvements project is one of 32 pipeline schemes being considered for possible inclusion in National Highways third Road Investment Strategy (RIS3) covering 1 April 2025 to 31 March 2030.
On 9 March 2023 the UK Transport Secretary ensured record funding would be invested in the country’s transport network, sustainably driving growth across the country while managing the pressures of inflation. The announcement cited the A27 Arundel Bypass as being deferred from RIS2 to RIS 3 (covering 2025-2030). The transport secretary also identified a number of challenges to the delivery of the road investment strategy and cited the benefit of allowing extra time to ensure schemes are better planned and efficient schemes can be deployed more effectively.
At present, there is no commitment by DfT to carry out the A27 Chichester bypass improvements project. Until the A27 Chichester bypass improvements project is published in the RIS3, consented and a decision to invest is made it cannot be assumed to be a committed project.
We note that the Plan does not address any uncertainty of delivery of the A27 Chichester bypass improvements project and we strongly recommend that there is either no reliance placed on RIS3 to realise capacity for growth in the Plan or that contingency measures are included to cover the eventuality that RIS3 funding is not forthcoming within the plan period. It is not clear that the potential impact of development on transport networks can be addressed in the absence of the A27 Chichester bypass improvements project.
Achieving net zero, reducing emissions reduction, acting on climate, and supporting thousands of new homes and new employment developments will be problematic with existing processes. New, additional, and adapted processes and assessments will likely be required, especially in assessing Transport Assessments, mandating Travel Plans and monitoring traffic associated with new developments. We acknowledge that change is complex, expensive, and time-consuming, especially for smaller district level Councils. But the hard work will deliver benefits for the Council and residents in the longer-term.
National Highways seeks to continue working with the Council and WSCC to progress coordinated and deliverable packages of interim mitigation measures and alternative transport solutions while a long-term strategic solution is considered by government. This must however be in combination with a robust monitor and manage policy that appropriately manages the risk of unacceptable road impacts resulting from new housing
and other development over the Plan period.

We have been in discussion with Chichester District Council regarding their proposed Monitor and Manage Strategy. At present, we do not consider the current strategy to be robust and we seek further information and detail especially on who, when and when monitoring and management will be undertaken. Developments in the right places and served by the right sustainable infrastructure delivered alongside or ahead of occupancy must be a key consideration when planning for growth in all local authority areas. Any M&M framework must be based on a “worst case scenario” whereby necessary transport mitigation is understood, as well as setting out the desired alternative scenario. It must set out details of responsibility, funding and governance of the framework together with the methodology for determining the timing for any mitigation delivery while remaining clear on the fallback position where identified mitigation or desired alternatives are not ultimately achievable. The M&M framework must set out that the alternative to mitigation not being delivered is that development does not proceed where that development would give rise to unacceptable road safety risk or severe cumulative impacts on the road network in the absence of that mitigation. The M&M framework must be translated into development management plan policy and policy relating to development allocations.
As we have reiterated throughout our comments, we welcome the opportunity to work with you to address these outstanding matters and we will continue to liaise over submitted Transport Assessment, Travel Plan policy and Monitor and Manage Policy to help to work towards a viable plan.
We hope our comments assist.
We look forward to continuing to participate in future consultations and discussions. Please do continue to consult us as the Plan progresses so that we can remain aware of, and comment as required on, its contents.
Once you have had the opportunity to digest all the representations received, we would welcome a meeting to run through all the transport related matters and agree how to progress any required evidence gathering or other work.

Entire Monitoring Framework needs a complete rethink and redraft with a view to seriously monitoring the delivery of the Local Plan and genuinely working across administrative boundaries with neighbouring authorities and agencies.

See attachment.

Thank you for the opportunity to comment on the Draft Chichester District Local Plan 2021-39. We would suggest that there has been insufficient public consultation to date. We commented on the draft Local Plan for 2015, on the Preferred Options in 2019 and there have been many changes in Government policy and commitments since then to include Climate Change, Net Zero and commitments made at COP 26 and 27 to include reducing methane emissions etc. With regards to this consultation we recognise the importance of a plan-led system and support Chichester District Council’s (CDC) desire to produce a comprehensive Local Plan. CPRE Sussex wishes to contribute to policies concerning landscape, rural areas, communities, environment and wildlife drawing on evidence and local knowledge.
CONTEXT
1. Examining the previous government consultation which closed on March 2nd, ie the Levelling-up and Regeneration Bill including some aspects of the National Planning Policy Framework, NPPF, there are some issues which would impact on this Local Plan and need consideration.
1.1 That consultation included important changes to the way in which the 5 year housing land supply is calculated, and the timetable for making Local Plans. They are of significance to local councils, especially those with Neighbourhood Plans. Some measures will take effect almost immediately through an update to the existing NPPF in Spring 2023. Others will follow later in the year or in 2024. Surely such consultations should be better phased to make plan development more logical and access to consultations easier?
2. Communities: Our group welcomed the overall shift in emphasis towards communities. Mind you, while the word is used 121 times in the Prospectus it does not appear in the draft NPPF! We would expect much more emphasis on the importance of communities in any forthcoming consult-ations. Earlier and more effective engagement with com-munities could help to lead to a less confrontational planning system with an emphasis on active participation.
3 Time required – a lot of time is needed to understand and implement such policies and a searchable on-line version would be very helpful; and, consideration also needs to be extended to those people in the community who are not computerised.
4 We take the word “sufficient” with regard to housing numbers to be equivalent to that which is “needed” and the current Standard Method does not establish that figure. Our MP, the Rt Hon Andrew Griffith, Arundel and South Downs, referred to the approach to developing housing numbers as a mutant algorithm.
4.1 Specifically, the changes to housing targets, to make them ‘advisory’, are welcome. However, we should remind you that the Government continues to insist on using out-of-date projections (2014). The current ONS population estimates are 1 million less people in the population than allowed for in the figures used to so that the reliance on the 2014 figures is completely out of date. The emphasis should always be on using current up to date evidence ……and to use those out-of-date figures produces the wrong results and does not conform with the need to use up to date information. In addition, this would require an immediate change to the guidance to insist (as previously) on the most up-to-date projections.
4.2 We also recommended a review of the Standard Method, which does not make housing affordable and simply supports developers to build market homes where they want to. The graph above illustrates the gap between projection and current population figure provided by the Community Planning Association.
4.3 Local Planning Authorities, LPAs, were also given an opportunity to put forward alternatives to the Standard Method and to name the specific constraints faced. Our contribution to that consultation referred to the:
- Reduction of land available to the CDC given the creation of the South Downs National Park, SDNP
- English Channel
- SDNP itself
- Range of internationally important designated sites
- Rare species and habitats
- River flood plains
- Water neutrality in part of the District
- Nutrient neutrality in the Solent
- Sea Level Rise
- Inadequate infrastructure – roads/lanes and local transport; sewage treatment; community facilities such as medical centres, shops; and
4.4 There have aleady been large housing commitments, loosely put on “flat green land” around Chichester and now CDC is eyeing the “empty” north of the District with allocations being made for Loxwood and an increase in the number of houses being sought in Wisborough Green. Such land supports wildlife which often may not be under recorded as it is private land. Areas in both of those Parishes has been “cleared” of biological interest but the BNG established a baseline of 2020 and google maps can show the state of the environment at that date. The commitment to safeguarding biodiversity needs to be pursued carefully and consistently.
COMMENTS ON THE CDC LOCAL PLAN 2021-2039 REG19 proposed submission comments: the comments cite the para and/or Chapter number
5. At this phase in the local plan process the scope of the invited representations is limited to whether the Plan that has been produced is:
a) legally compliant (i.e., whether it meets the legal requirements); and
b) sound (i.e., whether it has been positively prepared, is justified, is effective and is consistent with national policy) and I would ADD whether it is forward thinking enough as it is planned to last until 2039.
5.1 The plan area is split in to three areas, each with different characteristics, landscapes and access to services:
a) • The East-West Corridor, running across the width of the plan area, is varied in landscape with the inclusion of both larger settlements (including the city) and rural villages. It has the best transport connections and access to facilities in the plan area with the A27 and railway running through-out.
•b) The Manhood Peninsula* MP, located in the south of the plan area, jutting out into the English Channel, is rich in coastal landscapes with the majority of the area covered by environmental designations. It also includes some of the plan area’s larger settlements which rely heavily on limited road accessibility to the north towards Chichester city.
•c) The North of the Plan Area is primarily rural in character with diverse landscapes, rich cultural and heritage assets and a number of dispersed settlements, some of which are relatively isolated and served by narrow lanes with limited public transport
*NB The population on the MP is dispersed in a rural landscape and equals that of Chichester. The description for the North section could just as easily have been used for the MP.
Chapter 2 and Local Plan Vision
These Objectives will need to underlie every aspect of the document.
5.2 P 23: Para 2.25 Replace the word “site” by “area” and insert forming part of a diverse set of wetlands (Ditches, Rifes, Ponds, Saline lagoons and a small section of Canal). Info: The Medmerry site is no longer the largest eg having been overtaken in area by the Steart Marshes, Somerset.
5.3 Include mention of rare habitats and species and the role of Selsey Bill in facilitating arrivals and departures of bats, butterflies and birds. That’s its USP,
6.1 P 25 Local Plan Vision and Strategic Objectives p 30 Objective 1: CLIMATE CHANGE
Ths section does not reflect the urgency of the issue nor the vulnerability of parts of Sussex. Many scientists are pointing to Sea Level Rise, SLR, speeding up and some of them cite a 10 year window in which to act ie so that before this Local Plan has run its course, areas on the coast including the coastal plain and the Manhood Peninsula could well be adversely affected. This would have an immediate impact on housing, facilities and transport links and could lead to the local population having to move.
6.2 Actions related to this particular objective need to be included in all the following objectives. The south of the District is very vulnerable and the rest of the District will experience very intensive rainfall, water shortages (NE/EA 2013 report) and hot summers.
6.2 Policies need to include not building on areas below 5m high Water Level. The CDC Climate Change officer should host meetings to consider potential plans for putting houses on stilts, moving people to land safe from flooding and re-directing roads, cycle ways and footpaths to facilitate future access.
6.3 Evidence: See the Surging Seas and NASA websites for prediction of Sea Level Rise. Need to include reference to the UK Climate Resilience Programme jointly led by UK Research and Innovation, UKRI, and the Met Office which was set up to fund research “to help understand how to quantify the risks from climate change and build climate resilience for the UK, This research should produce “usable outputs” to “directly support decision-making” by government, local authorities, communities and other stakeholders
6.3.1 Every area of UK society will feel the effects of climate change and, as global emissions continue to rise, pre-paring for life in a warmer world is crucial. Findings were discussed last week by the UK ranging from assessments of elderly people overheating in care homes through to building community-run water storage.
6.3.2 Every area of UK society will feel the effects of climate change and, as global emissions continue to rise, preparing for life in a warmer world is crucial.
6.2.2.i In early March, UKTI and Met office researchers involved with the programme gathered to present and discuss their findings. They ranged from assessments of elderly people overheating in care homes through to building community-run water storage. These items and website need to be referenced in the evidence section.
6.3.3 The key points are intended to help businesses and policymakers adapt to climate change.
6.3.4 Many focused on “climate services” defined as involving the “production, translation, transfer and use of climate knowledge and information in climate-informed decision making”.
6.3.5 Climate services could be an important tool for adaptation because they can provide people with the relevant information to prepare for climate change.
6.3.6 Representatives from the Met Office laid out their recommendations for a UK National Framework for Climate Services. And said they wanted to provide a “driving force” for the nation’s climate services community and help ensure that “adaptation action actually does get done”.
6.4.7 UK ‘SSPs’
“Shared socioeconomic pathways” (SSPs) are tools used by researchers to explore how society will change in the future. This can help them to answer important questions about climate change. As there were no UK-specific versions of SSPs available to complement the UKCP18 climate projections
Ref: The importance of Adaptive Resilience Solutions in the Face of Climate Threats.
Recommendation: This report needs to be drawn on and form part of the evidence base.
7.1 Objective 2: NATURAL ENVIRONMENT Work with site managers of the Designated Sites and NGOs in the wider environment. This objective is vitally important and welcome and its importance needs to be reflected in all parts of the plan to include Wildlife Corridors, Biodiversity Net Gain and the Nature Recovery Network.
Sir David Attenborough
“It may sound frightening, but the scientific evidence is that if we have not taken dramatic action within the next decade, we could face irreversible damage to the natural world and the collapse of our societies.”
7.1.1 The emergency concerning Biodiversity also needs to be communicated.
Para 2.32: Agree – this (climate emergency) is the most urgent issue facing us all together with the Biodiversity Emergency (declared by IPBWS, 2019).
7.1.2 Info: The ESPACE project European Spatial Planning: Adapting to Climate Events (ESPACE) was a four-year project funded by the European Commission's north-west Europe INTERREG IIIB programme and the ODPM. It produced a Climate Action Plan for the Manhood Peninsula in 2008 and not much action has followed to implement this. Perhaps it needs dusting off and re-visiting and including within the Local Plan?
7.2 Add policy:
PROPOSED Ecosystem Services Policy
7.2.1 CPRE Sussex considers that the Chichester Local Plan 2021 - 2039 should include a policy specifically for Ecosystem Services for the following reasons:
1. NPPF para 174. Planning policies and decisions should contribute to and enhance the natural and local environment by:
a) protecting and enhancing valued landscapes, sites of biodiversity or geological value and soils (in a manner commensurate with their statutory status or identified quality in the development plan);
b) recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland
7.2.2 ‘Natural capital refers to the elements of nature that produce value to people –whether directly or indirectly. Our natural capital ‘assets’ are the stocks of renewable and non-renewable natural capital such as our soils, freshwater, farmland, forests, atmosphere, oceans, ecological processes and the natural processes that underpin them. The flows of ecosystem services and benefits that our natural capital provides can be very obvious such as food, fuel, clean air, clean water, and opportunities for recreation. Others are much less visible, such as climate regulation, flood defences provided by natural vegetation, the billions of tonnes of carbon stored by peatlands and other habitats and the pollination of crops by insects’. (Sussex Local Nature Partnership http://sussexlnp.org.uk/natural-capital/ )
7.3 Accordingly, we propose an Ecosystem Services policy (an adaptation of South Downs Park Authority’s Core Policy SD2: Ecosystem Services’), be added as follows:
1. Development proposals will be permitted where they have an overall positive impact on the ability of the natural environment to contribute goods and services. This will be achieved by means of high-quality design, and by delivering all opportunities to:
a) Sustainably manage land and water environments;
b) Protect and provide more, better and joined up natural habitats;
c) Conserve water resources and improve water quality;
d) Manage and mitigate the risk of flooding;
e) Improve the District’s resilience to, and mitigation of, climate change;
f) Increase the ability to store carbon through the retention of existing woodland, new planting or other means;
g) Conserve and enhance soils, use soils sustainably and protect the best and most versatile agricultural land;
h) Support the sustainable production and use of food, forestry and raw materials;
i) Reduce levels of pollution;
j) Improve opportunities for peoples’ health and wellbeing; and
k) Provide opportunities for access to the natural and cultural resources which contribute to the District’s special qualities.
2. The Environment Act 2021 will require the production of a Nature Recovery Network and more locally a Local Nature Recovery Strategy. The Strategic Wildlife Corridors in Chichester District will be integral components of that local network. The importance of local networks in Nature Recovery Networks is highlighted in NPPG
7.3.4 Policy NE 4 Strategic Wildlife Corridors
CPRE Sussex supports this policy, Strategic Wildlife Corridors as part of the Local Plan process, conform with section 179 of the NPPF 2021 which is well-evidenced. However, CPRE Sussex wishes to question the size of the corridors ie the width/
Information provided in the 2021 consultation appears to demonstrate that these areas have been downsized such as those put alongside the East of the City Corridor, it appears that there has been a narrowing of the Strategic Wildlife Corridor around the location of the proposed allocations of A8, Chapter 10: Strategic and Area Based Allocations Land East of Chichester and potential A7, Land at Shopwyke. The Corridor to the East of Chichester was proposed for connectivity and functional links to the area for the rare and European Protected Species of Barbastelle Bats. It is shown on CDC technical consultation documents as a bat network
This does not conform with the Natural Environment & Rural Communities Act, NERC, 2006 and Section 40 subsection 3a as it would destroy a habitat over which the Barbastelle Bat has been recorded, a Section 41 species. And it is the DUTY of the Local Authority to safeguard these species. There should be NO recreational use in the buffer zones.
8. Green Infrastructure: p 160 and Policy P 14 d Submission (Regulation 19)
8.1 Local Green Space
6.82. The NPPF includes the concept of Local Green Space designation. This is a discretionary designation and sites may be identified and included in either local or neighbourhood plans. The designation should only be used as defined by the criteria in the NPPF where the land is not extensive, is local in character and reasonably close to the community; and, where it is demonstrably special, for example because of its beauty, historic significance, recreational value (including as a playing field), tranquillity or richness of its wildlife. Any areas which fall outside a neighbour-hood plan area and where such designation is sought, will be considered by the subsequent Site Allocations DPD that will cover the remainder of the plan area. Policies for managing development within a Local Green Space should be consistent with those for Green Belts.
8.2 Parishes should be encouraged to look into such areas to be included in Neighbourhood Plans.
9. Renewable Energy: General policy
9.1 Housing p 103:
CPRE Sussex considers that the Chichester Local Plan should include a policy requiring all new-build homes to be equipped and sold with solar PV panels, roof or wall mounted.
9.2 Although the Chichester District Local Plan, at Para 6.15, states that ‘Design proposals should respond to the opportunities a site presents to make best use of solar gain where this can be achieved without compromising good urban design or creating issues of overheating’, there is no requirement in the any of the plan’s policies for new-build homes to be equipped and sold with roof or wall mounted solar PV.
9.3 Note that West Sussex County Council has advised in their Solar Together initiative that “By generating electricity from the sun, you could reduce your annual carbon emissions by approximately one tonne each year and help West Sussex to become carbon neutral”.
Note, too: https://solartogether.co.uk/westsussex/blog/best-ways-to-increase-solar-self-consumption
9.4 `“According to the University of Oxford findings, UK households with solar PV self-consume 45% of their own solar generation on average and reduce annual electricity demand from the grid by 24%. With additional adjustments, this reduction of 24% can be increased to over 35%”.
9.5`New-build homes in Chichester District should therefore be equipped with solar P V panels. We question the statement in Para 6.15 that ‘solar gain’ could create ‘issues of overheating’. Surely this can be prevented by good design?
9.6 There are additional opportunities for solar installations on school rooves (Brighton Sustainable Energy Co-op has many examples), car parks, industrial buildings et al.
10.0 Renewable Energy: Specific location Wisborough Green 75 additional houses. Unacceptable – see CDC Capacity Study sub sections 166+167. Limitations – Ancient woodland; wildlife – rare habitats and species, river floodplain; Water neutrality; HRA with reference to the Mens Ancient Woodland and presence of European Protected Species, Barbastelle Bats flight paths and foraging across the parish. See Natural England report Site Improvement Report and reports by Frank Greenway, 2008 et al.
10.1 See Page 84: In the north of the plan area, properties within Southern Water’s Sussex North Water Resource Zone are supplied with water from a groundwater abstraction at Pulborough which is currently subject to environmental investigations to ensure there is no adverse impact on environmentally designated sites in the Arun Valley. This may impact on the available supply and alternative sources may need to be considered by Southern Water. Natural England published a position statement in September 2021 requiring developments within the Sussex North Supply Zone to be water neutral – this means that the use of water in the supply area after the development is the same or lower than before. A Water Neutrality Strategy had been prepared jointly with other affected authorities. Natural England’s Position Statement sets out an interim approach based on minimising water use in new builds and offsetting the water that is used
10.2 Water consumption target. It is noted that both Ports-mouth Water and Southern Water have targets to reduce water consumption to 100 litres per person per day (lppd) by 2040, a lower figure than the current most stringent Building Regulation target of 110 lppd and not that level which could be required for water neutrality.
10.3 The Local Plan is weak on impacts especially from the largest concentration of caravans at Selsey on Medmerry.
10.4 There is no wildlife corridor running east to west along the Manhood Peninsula ie Pagham to East Head and this undermines the importance of a positive barrier zone to protect the habitat. CDC have used the corridors for this barrier purpose possibly more than as a pathway throughout other parts of the plan.
10.5 Nutrient neutrality exclusion of a large area of the Peninsula from the protection zone is illogical as the same conditions exhibited in Chichester harbour ( in the zone ) exist at Pagham.
10.6 There is a’tool’ - “nutrient budget calculator March, 2022 version” – which gives an “n” factor for instance to discharges from WWTW. There is no direct mention of its use at Chichester harbour and as the data on Pagham Harbour has yet to be made public, the role of Sidlesham WWTW has not been referred to. The “N” factor would probably be more restrictive on outflows from WWTW than the total discharge permits – and shows a lack of coordinated approach between the Environment Agency and Natural England.
10.7 There are two reports due to be published this month - the West Sussex Coast and Gt Brighton Board and Southern Water overall plan for drainage and waste water-the timing of the LP – is thus unable to take these two influential inputs into account and may have implications for the ‘Soundness ‘ of the plan as it moves forward.
10.8 No mention is included of Sidlesham WSTW which is operating at and beyond capacity resulting in new housing on the Manhood Peninsula dealing with waste water in gardens, in houses etc.
Pages 87 and 88: Paras 4.112 and 4.113 are contradictory.
Appendix F Monitoring Framework
Early in 2020 attended a Public Inquiry representing the Manhood Wildlife and Heritage Group and presented evidence about an application at Easton Farm where the implement-tation of an application had not been followed up, which had expanded like Topsy and which potentially could damage the Medmerry coastal realignment site with its runoff. CDC had not been on watch possibly through lack of staff and/or a lack of enforcement staff. The site had grown without permission. This section requires a firm commitment to monitoring and reporting back, not just a paper one.
Thank you for your attention.